Home Highlights July 2016 Year 2016 This

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1. TP Adjustment - international transaction - in the absence of no written agreement exists between the assessee and its AE requiring the assessee to incur AMP expenses,...

2. Transfer Pricing (TP) adjustments - Transfer Pricing (TP) adjustments - debar of deduction u/s 10A on addition income assessed u/s 92CD as per the Proviso to 92C(4) -...

3. TP Adjustment - excessive AMP expenses - third party also benefits - Revenue also could not demonstrate the presence of any machinery provision to compute Arm’s Length...

4. Transfer pricing adjustments - the discount and incentive passed by the assessee to its dealers and distributors on effecting the sales was required to be excluded from...

5. Transfer pricing adjustment in respect of Advertising, Marketing & Promotion (AMP) expenses -The assessee was a full fledge distributor and as such the benefit of AMP...

6. Adding back transfer pricing adjustment to income assessed u/s 115JB (MAT) - AO erred in adding back the transfer pricing adjustment of the book profits u/s 115JB - AT

7. Valuation - inclusion of advertisement and publicity expenses incurred by the dealers as per the terms and conditions of the dealership agreement mutually agreed between...

8. Transfer Pricing Adjustments - Purchase of Development Rights - capital transactions and their treatment - The tribunal addressed several crucial issues regarding the...

9. Transfer pricing adjustment - There can be no mark-up on reimbursement of expenses incurred by the assessee prior to incorporation of NDTV Network Plc UK - AT

10. Transfer pricing adjustments - Arm’s Length Price - The arbitrary selection of comparables has in fact inflated the operating profit in the computation made by the...

11. TP Adjustment - Provision of Administrative and Agency Services - Determination of Arm's Length Price (ALP) - allocation of expenses relating to income streams between...

12. TP adjustment - AMP expenses - the existence of an international transaction will have to be established de hors the BLT, the burden is on the Revenue to first show the...

13. Transfer pricing adjustment – export to associated enterprises of spares and components required for the purpose of servicing of vehicles sold by assessee - the...

14. Transfer pricing adjustment - The provisions were not incorporated to make adjustment at any cost and ignoring the basic facts - No adjustment to be made if transaction...

15. TP adjustment on interest on advances given to AEs - LIBOR + 260 basis points - the transactions of loans advanced to AEs by the assessee was adequately demonstrated by...